Recent safety violations: Remote devices, container distances
There are two recent items of concern: violations of off-truck remote devices and violations of required separation distances of containers from buildings and from sources of ignition.
Off-truck remote devices
Inspectors in North Carolina found violations of the off-truck remote device, causing activation of the emergency shutdown sequence for closing the internal valve and killing motive power while the truck was in driving mode.

The inspectors found five of these violations in one day and two more the next week. It’s important that the off-truck remote does not activate the shutdown system while the truck is being driven. There’s a significant risk of injury or death to the driver and others sharing the road when control is affected by inadvertent shutdown of the engine.
You should regularly check all of your trucks equipped with off-truck remotes to verify they are operating properly. You are probably checking them each morning to be sure they stop the engine and close the belly valve while the truck is parked, but you need to verify proper (non)operation when in travel mode. The system must shut down the engine when the parking brake is set. It must not shut down the system when the parking brake is not set. If it doesn’t operate according to these criteria, it needs to be fixed.
Please be aware that there is a requirement for a registered inspector to supervise and certify off-truck remote systems when they are installed or repaired. Also, there are manufacturer’s instructions for proper installation and testing of these systems. Failure of these systems to operate properly can put drivers and the public at a serious risk from multiple hazards. Proper operation of the off-truck remote system is part of the annual VK inspection, which, again, is performed by a registered inspector.
You can find the requirements for the off-truck remote system in 49 CFR § 173.315(n)(3). There is a safety advisory concerning when the system must not operate at bit.ly/fmcsa-remote.
These systems were first required about 25 years ago after a significant incident that resulted in an overall release of about 40,000 gallons of propane one Sunday afternoon. Fortunately, this was not a fire incident, as it happened just days after a major hurricane and power had not been restored.
There were early misunderstandings about the daily testing requirements, as some companies were requiring weekly testing. After that, testing went along fairly well, other than occasional missing remotes or dead batteries.
Recently, some inspectors interpreted the requirement to shut down “auxiliary power equipment” as including all electrical power. Discussions between the industry and Department of Transportation officials are being held to determine how to best resolve these differences of interpretation.

Container locations
Multiple violations about the required separation distances of containers from buildings and from sources of ignition were recently identified to us by building inspectors, fire inspectors and propane companies.
It appears, in some cases, that customers requested these containers be installed at improper locations, or they added onto their buildings.
Some of the violations resulted from containers being too close to HVAC units. These units are sources of ignition unless their electrical systems are electrically classified as Class I, Division 1 or 2, which is a rare occurrence.
It is often unclear which equipment was installed first – the propane container or the HVAC unit. Also, some of the violations were identified by building inspectors when an HVAC unit was replaced, with the new one placed at the same location.
There is no grandfathering in for this situation. If there was a violation that went unidentified when they were first installed too closely together, the same violation continues when either equipment is replaced. No rules that I know specify whose responsibility it is to correct these violations, only that they be corrected. Installers of the tanks and HVAC units are responsible for proper installation upfront. When they don’t take on that responsibility, they must provide the correction. The customer should not have to pay for these corrections, as the rules were not met at installation.
Drivers directed to make a delivery to a tank too close to a source of ignition or where there is a separation distance violation should question completing that request. They may be exposing themselves to an unnecessary risk or causing danger to customers. Instead, they should report the violation.
Richard Fredenburg is an LP gas engineer at the North Carolina Department of Agriculture and Consumer Services, Standards Division. He is also a member of NFPA’s Technical Committee on LP Gases. Reach him at 984-236-4752 or richard.fredenburg@ncagr.gov.
NOTE: The opinions and viewpoints expressed herein are solely the author’s and should in no way be interpreted as those of LP Gas magazine or any of its staff members.